Explanation of Privacy Principles in this Policy
General Collection and Use of Personal Information: We do not collect or use Personal Information such as a first and last name, physical address including a street name, e-mail address, telephone number, etc. (“Personal Information”) from any person on any of our sites with two exceptions:
We will use any Personal Information we collect for limited internal purposes that may include, but are not limited to, processing your transactions, establishing the identity of account holders, customer service, and providing you with information concerning our services. We will retain this information.
Forwarding of Personal Information: We may use the Personal Information we collect by sharing it with affiliates, vendors, contractors, and/or partners of Steele Compliance Wave (collectively, “Contractors”). We are not in the business of selling Company Information to third parties or Contractors, and will share it with affiliates or Contractors only as we describe below. In situations where we provide Personal Information to affiliates or Contractors, we ensure access is granted to the Contractors only on the condition that the Personal Information is kept confidential and is used only for carrying out the services such Contractors are performing for Compliance Wave. As part of making the determination whether we will provide Personal Information to affiliates or Contractors, we will obtain assurances that they will safeguard Personal Information consistent with this Policy.
We also reserve the right to disclose Personal Information if we are required to do so by law, or in the good faith belief that disclosure of the information is reasonably necessary to comply with legal process, to respond to claims, or to protect or advance the rights, property, safety, or well-being of our company, our employees, customers, or the public.
In the event that Steele Compliance Wave or substantially all of its assets are acquired, customer information, which may include Personal Information, may be one of the transferred assets.
Your Choice: We understand that you may not want to allow our disclosure of your Personal Information to our affiliates or Contractors, or to let us use that information for purposes that you believe may be incompatible with the purpose for which it originally was collected (as permitted by this policy) or that you later may authorize. Therefore, you may contact us to inform us that you do not want to permit these uses of your Personal Information. To do so, please contact us by mail or email at the address or email address provided above. It is not our regular practice to collect “Sensitive Information,” (e.g. credit card information, personal health information) but if we do, we commit that we will not disclose it to any third parties, including our affiliates or Contractors, or use that information for purposes that you believe may be incompatible with the purpose for which it originally was collected (as permitted by this policy) unless you expressly tell us that we can disclose that information or use it for those different purposes. In order for us to disclose it or use it for those purposes, you must contact us to inform us that you do permit these uses of your Sensitive Information. To do so, please contact us by mail or email at the address or email address provided above.
Security: Steele Compliance Wave will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Steele Compliance Wave has taken steps to ensure that Personal Information collected is secure, and we have limited the number of people who have access to the information by electronic security systems and password protections that guard against unauthorized access.
Collection of Non-Personal Information: We collect and use non-Personal Information, including IP addresses and web server log files to track trends, administer the website, track user movement on our sites, and gather demographic information. We use this non-Personal Information in the aggregate. We do not combine these types of non-Personal Information with Company Information.
Cookies and Web Service Log File Data: We may place a “cookie” or other tracking or information gathering device used in the industry in the browser files of a user’s computer. A cookie is a piece of data stored on the user’s hard drive containing information about the user. Cookies enable us to track and target the interests of our users to enhance the experience on our website. We are able to access only the cookies that our sites set on your computer and we are only able to determine the type of computer operating system and browser that you are using. We collect information from cookies and other information gathering devices and log files in the aggregate. We do not link the information collected through cookies or other devices to personal information that users submit online while participating in our activities. Users can set their browsers or third party software to reject cookies. If a user rejects the cookie, the user may be unable to use portions of our website.
Collection and Use of Information from Children: Steele Compliance Wave sites are not directed toward children. These sites are not designed to collect Personal Information from children.
Access: We want to assure you that you have access to any Personal Information that we collect and store. Customers may correct or amend information, or delete information that is inaccurate, or prevent their information from being used for purposes other than those for which it was originally collected. To do so, please contact us by written request or e-mail at the contact information stated above.
Enforcement: Steele Compliance Wave conducts periodic compliance audits of its relevant privacy practices to verify adherence to this policy. Any employee that Steele Compliance Wave determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
Joel Rogers, Managing Director
Compliance Wave LLC
241 Maple Avenue Suite 201
Red Bank NJ 07701
Effective Date: This policy was last updated on September 15, 2013.